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documentation to support the business deductions claimed on the
return. There is no record evidence to support that assertion,
and, even if there were, we are not persuaded that petitioner’s
preoccupation with establishing a new business would constitute
reasonable cause for failure to file timely his 1999 return. See
Polsby v. Commissioner, T.C. Memo. 1998-459; Estate of Bevan v.
Commissioner, T.C. Memo. 1989-256.
We uphold respondent’s determination that petitioner is
liable for the addition to tax under section 6651(a)(1) for
failure to file timely his 1999 return. The correct amount of the
addition to tax must be calculated as part of the Rule 155
computation.
To give effect to the foregoing,
Decision will be entered
under Rule 155.
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